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FTC Files Suit Against the Three Largest Pharmacy Benefit Managers

The Federal Trade Commission (FTC) recently sued the three largest pharmacy benefit managers (PBMs) – Caremark Rx, Express Scripts (ESI) and OptumRx – alleging that the PBMs and their related group purchasing organizations...more

Key Considerations in Utilizing a Letter of Intent in Health Care Transactions

A letter of intent (LOI), expression of interest (EOI) or term sheet is typically the first substantive document in the life of a transaction (noting that, oftentimes, parties will sign a nondisclosure agreement prior to...more

Spring Cleaning: Why Businesses Should Take Time Now to Review Corporate Records and Agreements

While the “spring cleaning” that typically comes to mind involves gardening, cleaning off the golf clubs or power washing, it is also an ideal time for business owners to take inventory of their corporate records, governing...more

New York Non-Compete Ban Vetoed but Proposal Lives On

New York Governor Cathy Hochul recently vetoed a bill that would have enacted a sweeping ban on non-competition covenants amidst increasing opposition from business groups cautioning that the legislation would accelerate the...more

New Annual Report Filing for PA Entities: What Should Businesses Consider?

As businesses, medical practices, nonprofit entities and other organizations begin working toward their 2024 goals, nearly all that operate through entities organized under Pennsylvania Law (as well as foreign entities...more

New York to Decide on Signing Non-Competition Ban into Law

New York businessowners and employees alike await a decision from Governor Kathy Hochul as to proposed legislation, which has passed in both the New York State Senate and General Assembly, that would ban most non-competition...more

Evading Transaction Roadblocks: Strategies for Common Late-Stage Dealbreakers

After completing the arduous task of preparing to sell a business and agreeing to the terms in principle for a transaction in which a business owner will sell his or her “life’s work,” selling business owners (“Seller” or...more

OIG Says Proposed Surgery Monitoring Arrangement May Violate Kickback Statute

On August 18, the Office of Inspector General in the Department of Health and Human Services (“OIG”) issued Advisory Opinion 23-05 in which it concluded that a proposed arrangement involving the formation of a company...more

Final Rule Ends COVID Vaccine Mandate in CMS-Certified Facilities

The United States Department of Health and Human Services (“HHS”), through the Centers for Medicare and Medicaid Services (“CMS”), published a final rule on June 5 (the “Final Rule”), which, among other important actions,...more

Practical Considerations of New NJ/NY Health Care Transaction Requirements

Recently, the Health Law Observer highlighted both implemented and proposed changes in requirements applicable to certain health care transactions in New Jersey and New York, respectively. Given the impact in both...more

Proposed NY Legislation Requires DOH Approval of Health Care Entity Transactions

The landscape of health care transactions has been constantly evolving and that holds particularly true at present. Recently, the Health Law Observer highlighted new requirements for “change in ownership” transactions in New...more

Reminder: NJ “Change of Ownership” Requirements for Health Care Transactions Have Changed

This year will mark the first full calendar year in which the Change of Ownership (CHOW) requirements added by New Jersey Senate Bill 315 (the “Bill”) will be in effect for certain health care transactions. Accordingly, it...more

Medicare Implications of the Omnibus Spending Bill

Last week, Congress passed the $1.7 trillion 2022 Omnibus Appropriations bill (the “Bill”) that funds the federal government through September of 2023 and Medicare is among the several areas addressed in the 4,000-plus pages...more

Selling Your Health Care Practice? Consider Timing and Effort Before Saying “Yes”

For a number of reasons, the calendar is among the most effective tools for advancing a transaction from “potential transaction” to a “closed transaction,” and that holds particularly true in the final months of the year. For...more

Overview of HHS Guidance on Audio-Only Telehealth Services

The COVID-19 pandemic accelerated the evolution of the role of technology in medical care, giving rise to novel issues in the absence of formal governmental guidance. Responding to certain challenges brought on by the...more

Policy Considerations for Voice-Controlled Devices Used in Senior Care Facilities

Over the last two years, the COVID-19 pandemic created a variety of challenges to both health care systems and the individuals they serve, but dire circumstances also fostered particular health care innovations....more

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